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Excel Homes Privacy Policy

Excel Homes Limited Partnership by its General Partner Excel Homes G.P. Ltd (referred to as “Excel Homes”, and also is referred to in this policy as “we”, “us”, or “our”) is committed to protecting and maintaining the privacy, accuracy, confidentiality, security and ethical use of Personal Information entrusted to us by our customers and prospective customers.

Our Privacy Policy applies to the collection, use, retention, maintenance and disclosure of Personal Information that Excel Homes obtains from customers and prospective customers. When we process Personal Information, we do so in accordance with the standards required by provincial and federal privacy and data protection laws. When we process personal data of individuals situated in the European Union, we do so in accordance with the privacy and data protection laws applicable to the European Union.

In addition, our Privacy Policy outlines the principles and practices we follow to protect Personal Information in accordance with the provisions of the applicable privacy protection legislation that Excel Homes is subject to. It also provides procedures for our customers and prospective customers to access or update their Personal Information or make a complaint regarding the handling of their Personal Information. Our Privacy Policy is also applicable to any person providing services on behalf of Excel Homes.

We may choose to update or amend our Privacy Policy at any time to reflect changes in our legal or regulatory obligations, or in the manner in which we deal with your Personal Information. We will post any revised version of this Privacy Policy on our website (www.excelhomes.ca) and we encourage you to refer back to our website on a regular basis. This Privacy Policy was last updated on July 11, 2018.

We collect Personal Information to enable us to provide our products and services to our customers and prospective customers in the course of our business activities.

Advertising and Analytics

About our use of Remarketing with Google Analytics

We also use Google Analytics to study the browsing behaviour of visitors to our website site. This is a website analytics service provided by Google Inc. Google Analytics collects information (via Cookies) on an anonymous basis, such as the number of visitors to our website, their country, region and city of origin, the type of browser and operating system they are using, the date, time and duration of visits, the pages consulted, and what other websites they visited prior to coming to this site. Our use of Google Analytics includes the Demographics and Interest Reporting component. This allows us to show remarketing advertisements for content or products that are most likely to interest you. We also use the Display Network Impressions Reporting component of Google Analytics, this allows us to collect information to evaluate how successful advertisements are. ;

Please note that you may opt-out of Google Analytics by installing the Google Analytics opt-out browser add-on (https://tools.google.com/dlpage/gaoptout) or by configuring your browser settings to block the use of cookies.

Facebook Conversion Tracking Pixel

We may also from time to time utilize the Conversion Tracking Pixel service of Facebook. This tool enables us to follow and understand the actions of users after they are redirected to a provider’s website by clicking on a Facebook advertisement and allows us to understand and deliver ads to you that are more relevant to you. The data that is collected remains anonymous which means we are not able to see the personal data of any particular individual user. However, the collected data is saved and processed by Facebook. Therefore, Facebook may be able to connect that data to your Facebook account and use the data for their own advertising purposes in accordance with Facebooks own data use policy found at: https://www.facebook.com/about/privacy/). You can opt-out of Facebook’s use of cookies and the Conversion Tracking Pixel be clicking here: https://www.facebook.com/help/568137493302217.

The 10 Privacy Principles from the Canadian Standards Association - Model Code for the Protection of Personal Information

Excel Homes abides by the Model Code for the Protection of Personal Information in collecting, using and disclosing Personal Information:

Principle #1 - Accountability and Protection of Personal Information

Excel Homes is responsible for Personal Information under its control.

Accountability for compliance with our Privacy Policy rests with the Senior Management of Excel Homes but, all employees are trained to appreciate the importance of privacy and confidentiality of Personal Information and are required to comply with the provisions of this Privacy Policy as a condition of their employment. Excel Homes has designated the following person to act as Privacy Officer:

Excel Homes collects, uses, retains and discloses Personal Information as necessary to establish and manage our relationship with customers and prospective customers to provide home building services. Specifically, we may collect, use, retain and disclose Personal Information for the following: (“identified purposes”):

to provide information necessary to build your home;

to provide necessary financial information;

to establish and maintain a customer relationship;

to enter into a home building contract with you (the “Contract”);

to assess and provide ongoing maintenance and customer care relating to your home;

to register your home with The Alberta New Home Warranty Program (the “Program”; and

to comply with legal and regulatory requirements.

If you would like to receive further details regarding the “identified purposes”, please contact our Privacy Officer.

If you contact us through our website, or provide us with your contact information in the course of our efforts to market our products and services to you, we may also contact you via an email message or other media to:

respond to an inquiry, or request for information;

thank you for contacting Excel Homes;

welcome you to Excel Homes and to its products and services;

explain product offerings and features of our services;

notify you of any special promotions, contests, draws or other special events;

communicate with you after your home is built and your use of any of our related products and services; and

contact you after your home is built regarding warranty services.

Excel Homes does not use Personal Information to make automated decisions.

We do reserve the right to collate/process and disseminate statistics based on the aggregation of data held in our files, provided that information relating to any individual customer or prospective customer will not be identified from the resulting analysis.

Certain Excel Homes employees, contractors and consultants may be given access to Personal Information in so far as their duties require access for the identified purposes. Their access to customer or prospective customer Personal Information is on a need to know basis.

Principle #3 - Obtaining Consent for Collection, Use or Disclosure of Personal Information

Your knowledge and consent is required for the collection, use or disclosure of Personal Information, except where inappropriate, or where required or permitted by law.

Your consent

Your consent may be implied or express. Implied consent is consent that can reasonably be inferred from your action or inaction. For example, when you enter into a Contract with Excel Homes, or you submit a registration or survey form to Excel Homes, we will assume your consent has been provided to the collection, use and disclosure of your Personal Information for all identified purposes as set out in this Privacy Policy.

Please note that Excel Homes does not sell, trade or rent Personal Information to any organization for any purpose.

If we plan to use or disclose your Personal Information for a purpose not for one of the identified purposes, we will endeavour to advise you of that purpose and obtain your express consent prior to such use or disclosure. Your express consent may be provided orally, electronically or in writing.

Withdrawing your consent

You may withdraw your consent at any time to our collection, use or disclosure of your Personal Information, subject to any legal or contractual restrictions and with reasonable notice. In order to withdraw consent, you must provide notice, in writing, to the Excel Homes Privacy Officer identified under Principle #1. Upon receipt of such notice Excel Homes shall inform you of the implications of withdrawal, for example you may not be notified about associated services and products.

Our collection, use and disclosure of Personal Information shall be limited to the purposes identified in this Privacy Policy.

Excel Homes collects most Personal Information directly from its customers, and occasionally from third parties such as realtors, mortgage brokers or financial institutions.

Similarly, our customers Personal Information may be disclosed for identified purposes to necessary third parties such as for the Program, and for contractors, trades, mortgage brokers or financial institutions.

Under European Union privacy and data protection laws, the use of Personal Information of individuals situated in the European Union must be justified under at least one of a number of legal grounds. The principal legal grounds that applies when we use or disclose the Personal Information of EU citizens are as follows:

performance of the Contract (where your Personal Information is necessary to enter into or perform the Contract with you);

a legitimate interest (where we use your Personal Information to achieve a legitimate interest and our reasons for using it outweigh any prejudice to your privacy and data protection rights);

a legal claim (where your Personal Information is necessary for us to defend, prosecute or make a claim against you, us, or a third party); and

consent (where you have consented to our use and disclosure of your Personal Information).

Principle #5 - Retention

Personal Information shall be retained by Excel Homes for as long as reasonably necessary to fulfill identified purposes or as may be required by law.

Principle #6 - Accuracy

It is important that Personal Information collected by Excel Homes and in its records shall be accurate, complete, and up-to-date as is reasonably necessary, for the purposes for which Personal Information is to be used. If your Personal Information changes during the course of your relationship with us, please keep us informed of such changes and we will update that record.

Principle #7 - Security Safeguards

Excel Homes will use reasonable methods to protect the security of Personal Information in its custody and under its control, with physical, administrative and technological safeguards, as appropriate.

Excel Homes shall protect Personal Information disclosed to third parties by requiring third parties to comply with our Privacy Policy and limiting the purposes for which the Personal Information can be used.

Excel Homes uses sales management software that utilizes cloud storage of data in the U.S. We have satisfied ourselves that the data is secure and properly protected to the standards required by the applicable legislation.

Principle #8 - Openness Concerning Policies and Practices

Excel Homes shall make specific information about the principles and practices relating to its handling of Personal Information available on request. This Privacy Policy is available online or in hard copy format from our Head Office.

Principle #9 – Customers’ Access to Personal Information

Upon request, you are entitled to access the Personal Information which we hold about you. You are entitled to challenge the accuracy and completeness of this Personal Information and have it amended, if appropriate.

How can I access my Personal Information?

You can make a written request to the Privacy Officer, and upon presentation of satisfactory identification, Excel Homes shall take all reasonable steps to gather the Personal Information requested.

Within 45 days of receiving your request, Excel Homes shall provide a written response detailing whether access will be given to all or part of the requested Personal Information and explain the reasons for the refusal, should any part of the access request be refused.

When an individual successfully demonstrates the inaccuracy or incompleteness of Personal Information, Excel Homes shall amend the information as required, subject to any applicable legal limitations.

Principle #10 - Challenging Compliance, Handling Customer Inquiries

Excel Homes shall investigate all complaints concerning compliance with this Privacy Policy. If a complaint is found to be justified, Excel Homes shall take appropriate measures, including, if necessary, amending its policies and practices.

If you feel that your concerns have not been adequately addressed, Excel Homes will provide you with information regarding alternative complaint procedures that may be available to you. You may be advised to seek advice from the Office of the Privacy Commissioner of Alberta at 1-888-878-4044.

Please note that Excel Homes may seek external legal advice where appropriate before providing a final response to individual complaints.

Additional Rights you may have in relation to your Personal Information

In addition to the right to access and update your Personal Information as set out in this Privacy Policy, under certain circumstances individuals situated in the European Union have additional rights in accordance with data protection laws to require us to:

provide you with further details on the use we make of your Personal Information;

upon request and in certain legally permissible circumstances, delete any Personal Information about you;

port your Personal Information to another service provider upon request and where legally permissible;

where data processing is based on consent, to withdraw your consent such that we stop that particular processing; and

restrict how we use your Personal Information while a complaint is being investigated.